Breadcrumb
Throughout 2021, members of the Provost’s Office, the Office of Data Analytics, the deans, Human Resources, and campus financial unitsworked together to identify gender and race and ethnicity salary inequities under the Colorado Equal Pay for Equal Work Act law’s provisions.
Regular Faculty
All regular faculty positions (i.e., tenured faculty, tenure-track faculty, instructor-track faculty and clinical faculty) were reviewed and grouped into substantially similar job families by department, division or school/college. A statistical model was then used to determine predicted salaries using variables including years since highest degree, years in rank, discipline, and other inputs.For a detailed explanation of the assessment methodology and the review process, see CU Boulder CEPEWA Faculty Methodology and Appendix A and Appendix B.
Tenured and tenure-track faculty salary differences could typically be explained by one or more of the following reasons, all of which are allowed by law:
- The faculty member’s academic department/program, which is a factor indicative of substantially similar work
- Years since the faculty member obtained their highest degree, which is a factor indicative of job-related experience
- The number of years the faculty member has been in their current rank (e.g., full, associate, or assistant professor), which is a factor indicative of job-related experience
- The total number of years the faculty member has been employed in a tenured or tenure-track position at CU Boulder, which is a factor indicative of job-related experience
- Whether the faculty member has received a retention offer, which is a factor indicative of job-related experience, quality and quantity of production, and exceptionally high merit
- The number of additional appointments the faculty member has had (e.g., a chair or director appointment), which is a factor indicative of job-related experience and quality and quantity of production
- The faculty member’s average merit score over the past five years in comparison to the average score of other faculty members in the same department, which is a factor indicative of pay differentiation on the basis of a merit system
- Other factors similar to the above that are particular to a certain academic discipline (e.g., Law or Libraries), as detailed in the explanation of the process used to review faculty salaries
For instructor-track and clinical faculty, salary differences could typically be explained by one or more of the following reasons, all of which are allowed by law:
- The faculty member’s academic department/program, which is a factor indicative of substantially similar work
- Years since the faculty member obtained their highest degree, which is a factor indicative of job-related experience
- The number of years the faculty member has been in their current rank (e.g., senior instructor v. instructor), which is a factor indicative of job-related experience
- Total number of years serving as instructor and senior instructor or as a clinical faculty member at CU Boulder, which is a factor indicative of job-related experience
- Total number of years serving as instructor and senior instructor or as a clinical faculty member at CU Boulder, which is a factor indicative of job-related experience
- Whether the faculty member was hired within the 12 months previous to September 2021, which is a factor indicative of job-related experience
- The number of additional appointments the faculty member has had (e.g., a director or associate director appointment), which is a factor indicative of job-related experience and quality and quantity of production
- Other factors similar to the above that are particular to a certain academic discipline (e.g., Law or Libraries), as detailed in the explanation of the process used to review faculty salaries
In cases where a faculty member’s actual salary is below the salary predicted when using the criteria listed above and where a gender or race/ethnicity disparity exists, preliminary analysis flagged the faculty member’s salary for an increase to the predicted salary level. Deans and other school/college leaders then reviewed the preliminary analysis to correct errors and provide qualitative analysis. The goal was to ensure that faculty pay differences for substantially similar work within the home discipline/department are not discriminatory based on protected class gender or race/ethnicity. No salaries were decreased as a result of this analysis.
Research Faculty
Salaries for positions in the faculty series are being reviewed within each institute, school and college based on the type of work and the nature of the project and grant. Employees identified for adjustments will be notified directly on a rolling basis as each area completes its analysis. No salaries will be decreased as a result of this analysis.
Equity Review Methodologies
General Questions
- What is the Colorado Equal Pay for Equal Work Act?
- How does this apply to CU Boulder?
- What was CU Boulder’s process to comply?
- Who is paying for these salary adjustments?
- Will this be a one-time correction, or will it occur every year?
- When will I be notified if I am receiving an equity increase?
- In what paycheck will I see the equity increase?
- What is CU Boulder doing to correct salary inequities that are not related to sex or race?
- Why weren’t other protected statuses like disability or sexual orientation included in the CEPEWA analysis?
- Is it discriminatory for CU Boulder’s Colorado Equal Pay for Equal Work Act review to focus on sex and sex plus protected class status?
- What is the pay equity review process for lecturers, adjuncts and other similar faculty?
- What is the pay equity review process for student employees?
- What are CU Boulder’s standard practices to correct salary inequities?
- What can a faculty or staff member do if they do not believe they are being paid equitably?
- CEPEWA amends Colorado law and provides new wage discrimination and employer provisions that differ from federal law and other state equal pay laws. It applies to all employers and employees in the state of Colorado, both public and private, and went into effect Jan. 1, 2021.
- The prohibits “wage discrimination based on sex.”
- As a Colorado employer, CU Boulder must comply with the Colorado Equal Pay for Equal Work Act.
- The CEPEWA aims to address a larger history of gender and race/ethnicity wage disparities includingfor faculty and staff within higher education.
- Through its Human Resources (HR) and Data Analytics (ODA) departments, CU Boulder has identified and is correcting wage differences within its female and underrepresented faculty and staff populations.
CU Boulder’s process to comply included:
- Determining job categories for substantially similar work
- Identifying female and underrepresented pay inequities within each substantially similar group as determined by a consistent and systemic data analysis
- Correcting identified pay inequities in January 2022
- Ensuring job postings include the law’s required elements, such as the pay rate or range
- Updating compensation policies and procedures to ensure ongoing compliance
The campus has set aside a budget for general fund positions to address salary adjustments required for compliance by the Colorado Equal Pay for Equal Work Act. Adjustments for non-general fund positions will need to be covered by auxiliary, grant or gift funds. Future increases will need to be covered by the department, schools and colleges.
This one-time increase will correct the identified inequities.
Employees eligible for an annual pay increase or for an equity increase will receive a salary email notification by the end of January 2022.
Equity increases will be included in the January 2022 end-of-month paycheck.
Campus leaders, Human Resources, the Provost’s Office and the Office of Data Analytics will continue to review salaries and market trends as part of the annual compensation increase exercise to keep employee pay competitive.
The campus does not have complete or uniform data available for employees for other protected statuses beyond sex/gender and race/ethnicity and therefore is not able to include that additional information.
CU Boulder complied with the Colorado Equal Pay for Equal Work Act requirements by reviewing salaries for discrepancies based on sex or sex plus another protected status. This sex or “sex plus” review was necessary to ensure compliance with Colorado’s new law. Individuals who are concerned about their salary but who did not receive an adjustment based on CEPEWA criteria may raise their concerns with their supervisor,chair, campus HR, or the OIEC.
Salary rates for lecturers, adjuncts and other similar faculty are set by the school or college and based on the courses taught. The campus will continue to work with the schools and colleges to ensure pay levels for this work are set equitably.
Salaries for student employees are determined by the type and level of work assigned by the hiring department, school or college and by the experience or length of service of the employees, if applicable, and follow campus pay-setting policies, procedures and guidelines. The campus will continue to provide guidance to hiring units about setting pay consistently and equitably for student employees performing substantially similar work in their areas.
- With assistance from ODA, the campus performs a salary equity analysis for faculty by rank, gender, and race/ethnicity.
- Campus HR advises hiring units on an appropriate pay range and starting salary level for staff positions based on the nature of work, level/scope of the job, and job related experience, education, licensure, training or certifications.
- Units may set aside a portion of the annual merit increase pool or use accumulated salary savings to address inequities for their employees.
- Each unit is required to have a salary grievance process for faculty, which includes a process to escalate a request beyond the unit if the employee is not satisfied.
- Staff employees can reach out to their unit’s HR team or the Boulder campus human resources compensation team. An online question form is available.
- Employees who believe they have been unlawfully discriminated against with their compensation or have experienced or witnessed a violation of this policy shall promptly report the matter to the Office of Institutional Equity & Compliance (OIEC). This includes supervisors and other responsible employees required to report under campus policy.
Faculty Questions
- What methods did CU Boulder use to review the Colorado Equal Pay for Equal Work Act compliance for faculty?
- My department’s faculty merit system/salary procedures are unique to it. Why didn’t you tailor your methodology to each unique merit system?
- My salary seems low compared to faculty salaries in my discipline and rank at peer institutions.
- My salary seems low compared to other faculty in my department/program, division, or school/college.
- What was the methodology that determined the amount a faculty member’s salary should be?
- Why was this methodology chosen instead of another?
- Why hasn't this model caught these equity differences before now?
- Why did the model use five years of merit scores instead of more in cases where a faculty member has been here longer than five years?
- Why is it allowable to consider whether a faculty member received a retention offer as a factor in their salary level?
- How will I learn if I am eligible?
- Why was decreasing higher salaries to resolve pay differences with lower salaries not considered in the model?
- What is the university’s faculty salary grievance policy?
- How can I find out what happened with my specific salary in the analysis?
- How many faculty members received a salary equity increase?
- What was the average increase amount?
- What is the impact of the Colorado Equal Pay for Equal Work Act on the phenomenon of outside job interviews and offers and the retention offers that units may provide to a faculty member as an incentive to stay at CU Boulder?
- All regular faculty (i.e., tenured faculty, tenure-track faculty and instructor-track faculty) positions were reviewed and grouped into substantially similar job families by department, division or school/college.
- Salary differences could typically be explained by one of the following reasons:
- Department
- Years since highest degree
- Years in position
- One or more retention offers since 2011
- Number of appointments
- Average merit score over the past five years in comparison to the average score of other faculty members in the same department
- For a detailed explanation of the assessment methodology and the review process, seeCU Boulder CEPEWA Faculty MethodologyandAppendix AandAppendix B.
- Salaries for faculty in the research faculty series are being reviewed within each institute, school and college based on the type of work and the nature of the project and grant. Employees identified for adjustments will be notified directly on a rolling basis as each area completes its analysis.
The model takes into consideration average merit scores in each academic department. The average department score is compared to a faculty member’s average merit score and score dispersion over all faculty members in the department over the same period. Then this score is standardized to allow for use across academic units.The results of each department’s unique scoring system are reflected in the use of both the average department score and the score dispersion across the department.
The CEPEWA review was specific to the law’s requirement to identify and address protected class gender and race/ethnicity pay inequities. This requires an internal analysis and comparison across employees performing substantially similar work on campus. Market forces and compression issues are outside the scope of this initial analysis. Units may continue to use existing resources and existing campus processes to address pay level concerns in their areas in collaboration with their school/college, the Office of Faculty Affairs and Academic Resource Management.
Faculty members may raise salary level concerns with their department chair or dean, who will review the concern and provide further information.
A faculty member’s predicted salary is based on inputs including their primary unit (department/program), school/college, A&S division, years since highest degree, years in current rank, and number of total appointments (e.g., chair, associate director), plus additional factors for tenured and tenure-track faculty including the most recent five years of annual merit scores and whether the faculty member has received a retention offer.For a detailed explanation of the assessment methodology and the review process, seeCU Boulder CEPEWA Faculty MethodologyandAppendix AandAppendix B.
This methodology is a refinement ofhow the campus has previously reviewed faculty salaries for equity and also meets the requirements of Colorado’s law. It was originally developed a decade ago based on influential research by CU Boulder faculty members and with input from the faculty Academic Affairs Budget Advisory Committee.
CU Boulder’s annual salary equity analyses have examined faculty salaries in larger aggregations (campus-wide, and by college/school) instead of assessing pay inequities related to gender and racial or ethnic group at the unit level. Due to the review requirements of the Colorado Equal Pay for Equal Work Act, the existing annual analysis model was enhanced to include additional variables relevant at the unit level and was used to assess faculty salary trends in individual departments/programs or in divisions of colleges/schools. For purposes of the EPEWA salary analysis, Institutional Research also extended the revised methodology to analyze the salaries of instructor-track and clinical faculty members along with those of TTT faculty members. This refined and more granular review revealed inequities specific to the unit level.
Institutional Research examined various options to see how merit scores predicted current salary. Five years of merit scores were more accurately predictive of current salary than longer spans of time (e.g., ten years, fifteen years, or entire career at CU Boulder).
CU does not have a mechanism as a normal part of the annual review process that recognizes exceptionally high merit. Responding to an external offer with a salary increase is a form of recognizing exceptionally high merit.
Employees eligible for an equity increase will receive a salary email notification by the end of January 2022.
The campus determined that increasing salaries to address pay inequities was a more appropriate means of complying with the law.
For faculty members who have salary grievances, the Boulder campus maintains a faculty salary equity appeals committee for the resolution of salary grievances and oversight of the appeals process. This committee reviews any appeal regarding salary equity that has not been resolved at either the primary unit or college/school level. Please refer to the Office of Faculty Affairs website for information about faculty salary grievance processes.
Eligible faculty will be notified by the end of January if they are receiving a salary equity increase. Faculty ineligible for a salary equity increase on the basis of the Colorado Equal Pay for Equal Work Act either had salaries at or above the predicted level or were not in the groups covered by the law for equity adjustments based on sex or sex-plus-protected-class. Going forward, the campus will work to support schools, colleges, and other academic units with additional analysis and tools to gauge factors affecting salary equity for all faculty, including compression and market forces.
As of Jan. 20, 479 faculty members were identified for an equity increase.
The average increase to the base salary for faculty equity was $6,612.
Retention offers are still possible. Responding to an external offer with a salary increase is indicative of job-related experience, quality and quantity of production, and exceptionally high merit, all allowable under this law. In addition, as part of our further review of salary-related processes and procedures in spring 2022 and academic year 2022-23, we will examine retention offer practices.
Staff Questions
- What methods did CU Boulder use to review the Colorado Equal Pay for Equal Work Act compliance for staff positions?
- My salary seems low compared to other jobs I see advertised outside of CU. What is being done to address that?
- I am concerned that other employees who do the same job as I do have been hired at higher rates. How do I raise this concern?
- I believe my position description is not accurate. How can I address that?
- How will I learn if I am eligible?
- How many staff members received a salary equity increase?
- What was the average amount?
- How can I find out what happened with my salary in the analysis?
- All regular classified and university staff occupied positions were reviewed and grouped into substantially similar job families. This review included position description content, supervisor and HR liaison input, payroll job code, working title, salary, job-related experience at CU, time in current role and annual performance ratings, if applicable. Education, external experience, licensure, certifications, specialized skills or training were also reviewed if relevant to the role, such as for psychologists, behavioral health counselors, nurses and physicians.
- Salary differences could typically be explained by one or more of the following reasons, all of which are allowed by law:
- Job family (nature of work)
- Level or scope of the role
- Time in the role
- Relevant experience at CU
- In those cases where salary differences could not be explained by one or more of the criteria listed above and where a gender or race/ethnicity difference existed, the employee’s salary was flagged for an increase to the level of the higher paid substantially similar job. The goal was to ensure that staff pay differences for substantially similar work are not discriminatory based on protected class gender or race/ethnicity
- No salaries were decreased as a result of this analysis.
The CEPEWA review was specific to the law’s requirement to identify and address protected class gender and race/ethnicity pay inequities. This requires an internal analysis and comparison across employees performing substantially similar work on campus. Market forces and compression issues are outside the scope of this initial analysis. Units may continue to use existing resources and existing campus processes to address pay level concerns in their areas in collaboration with campus HR.
Employees may raise salary concerns with their supervisor, their unit HR team, and/or campus HR. Campus HR will review the concern and provide further information. Note that jobs may appear to be similar in a job posting but may not actually be similar when reviewed in more detail including the impact of decision authority, scope and sphere of influence, level of independence, span of control, complexity and other factors. The supervisor, unit HR or campus HR can provide clarification and information.
If an employee or supervisor believes a position description is out of date, they should start with updating the position description content in the . The supervisor is accountable for assigning the work and needs to be involved in the review process. Once updated, the content will route for department and campus HR review and approval.
Employees eligible for an equity increase will receive a salary email notification by the end of January 2022.
As of Jan. 20, 250 staff employees were identified for an equity increase.
The average increase to the base annual salary for staff equity was $4,086.
Employees may raise salary concerns with their supervisor, their unit HR team, and/or campus HR. Campus HR will review the concern and provide further information.
Equal Pay for Equal Work Act Questions
To ensure that your question is addressed by the appropriate campus office, please complete theCU Boulder Employees Compensation & Equal Pay for Equal Work Act Questions web form.
*Note: The form requires you to sign-in using your IndentiKey. Please click onYou mustloginto view this format the top of the web form page.